Before the Federal Communications Commission

Washington, D.C. 20554

In the Matter of

Telecommunications Carriers Eligible To Receive Universal Service Support

Lifeline and Link Up Reform and Modernization

) ) ) ) ) ) )

WC Docket No. 09-197

WC Docket No. 11-42

BOOMERANG WIRELESS, LLC REVISED COMPLIANCE PLAN

Boomerang Wireless, LLC d/b/a Ready Mobile C'Boomerang" or the "Company'') is a prepaid

wireless telecommunications carrier seeking designation as an eligible telecommunications carrier

C'ETC'') for the limited purpose of offering service supported by the Lifeline program.1 Boomerang

seeks to avail itself of the Federal Communications., Commission's (''Commission'') grant of

forbearance from the "own-facilities" requirement contained in Section 214(e)(1)(A), 2 subject to

certain conditions set forth in the Commission's Order released February 6, 2012.3 Specifically, the

Commission provided that a carrier seeking to become a Lifeline-only ETC must comply with certain

911 requirements and file a compliance plan "providing specific information regarding the carrier's

1 Boomerang currently has pending a petition for designation as a Lifeline-only ETC in certain states. See Amended Petition of Boomerang Wireless, LLC for Designation as an Eligible Telecommunications Carrier in Alabama, Connecticut, Delaware, the District of Columbia, New Hampshire, New York, North Carolina, Tennessee and Virginia, WC Docket No. 09-197 (filed June 6, 2012) (''Petition''). Boomerang seeks authorization to provide Lifeline-only service to residents of Tribal lands as well. Boomerang respectfully requests to incorporate the commitments made herein into the pending Petition. 2 47 U.S.C. § 214(e)(1)(A). 3 In the Matter of Lifeline and Link Up Reform and Modernization, Lifeline and Link Up, Federal-State Joint Board on Universal Service, Advancing Broadband Availability Through Digital Literacy Training, WC Docket No. 11-42, WC Docket No. 03-109, CC Docket No. 96-45, WC Docket No. 12-23, Report and Order and Further Notice of Proposed Rulemaking, FCC 12-11 (rel. Feb. 6, 2012) (''Lifeline Reform Order'').

. service offerings and outlining the measures the carrier will take to implement the obligations

contained in [the] Order."4

Boomerang submits this Revised Compliance Plan (''Compliance Plan'') to detail the policies,

procedures and training programs it has developed to guard against waste, fraud and abuse in the

Lifeline program. This Revised Compliance Plan is intended to replace Boomerang's previously filed

compliance plan. Boomerang has continued to refine its planned policies and procedures for

enrolling eligible Lifeline customers and providing Lifeline services in accordance with the

Commission's Lifeline rules, has formed partnerships and has formulated and adopted internal

policies, procedures and training materials in line with the Commission's Lifeline reform. This

Compliance Plan discusses in more detail Boomerang's plans for qualifying and enrolling eligible

customers, includes more specifics about how Boomerang will review eligibility documentation and

guard against households receiving duplicate subsidies, and the process for service activation in

compliance with the Commission's new rules ..

In this Compliance Plan, Boomerang will describe in more detail the mechanisms and

partnerships it already has in place to prevent duplicate benefits to the same household. Above and

beyond meeting the Commission's requirements for guarding against duplicates, Boomerang will go

a step further in its outreach by targeting currently unserved/underserved populations. A

substantial market segment has not yet been reached by current ETCs. As a result, millions of

eligible citizens need Lifeline-supported services but are not currently served by the program.

Boomerang has partnerships and established marketing outreach experience and future plans to

target this underserved population. This effort, together with Boomerang's procedures to prevent

duplicate subsidies, will serve the important public policy goals of the program to extend critical

services to Americans with the greatest needs.

Boomerang's business model, ethos and objectives support the Lifeline program and its

goals. Boomerang's commitments to comply with the Commission's Lifeline rules serve the program

4 Lifeline Reform Order ~ 368.

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and allow the Company to invest its capital in consumers who meet program eligibility requirements

now, but who require reliable, innovative, high quality services for the long haul. Boomerang is

continuously refining and improving its practices and procedures for satisfying all of the

Commission's Lifeline requirements in order to build a successful Lifeline business that serves

customers with the greatest needs.

Background

Boomerang is one of three wholly owned subsidiaries of HH Ventures LLC, an Iowa

company. 5 The other two subsidiaries are enMarket, LLC (''enMarket'') and Ready Wireless, LLC

(''Ready Wireless''). HH Ventures LLC (''HH Ventures'') is a profitable, cash flow positive wireless

telecommunications holding company, which employs forty full-time employees. The company's

core management team includes six senior executives with more than 100 years of combined

telecom experience.

Boomerang seeks ETC designation in order to provide handsets and domestic and

international voice services to low-income customers. Boomerang also intends to provide Lifeline­

only service to residents of Tribal lands. Boomerang has direct, network carrier contracts with Sprint

and Verizon, and is also negotiating a contract with a national GSM provider. The multi-carrier

wireless network platform provides robust wireless service coverage across the entire ETC footprint.

Boomerang has direct, in-depth experience with building voice, data and broadband products

directly with carriers.

HH Ventures formed enMarket in January 2012 to focus on event marketing and distribution

for ETCs. Full time employees create neighborhood events to build awareness of the Lifeline

program and to distribute phone services to eligible consumers. Event staff is trained on the

program compliance requirements, as detailed more fully below, and creates a positive community

experience. The company also diligently implements measures to prevent waste, fraud and abuse.

5 See Exhibit A for HH Holdings structure, ownership and brands.

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In addition, the company has a national partnership to participate in Medicaid managed care

organization community events in order to reach a population with significant needs for access to

services. This unique partnership with organizations who serve Medicaid recipients is designed to

reach in person transient consumers and those who otherwise do not have access to the online,

telephone, or paper application process unless supported by another person at an in-person event.

Again, as detailed below, employees who engage with potential subscribers at these events receive

detailed and extensive training in the Commission's Lifeline eligibility, documentation and other

requirements, and how to communicate these requirements clearly to potential subscribers.

Ready Wireless offers an MVNE wholesale platform for ETCs and other non-ETC white label

partners as well as for the companies' own retail brands Ready Mobile, Ready Broadband and

Trumpet. The platform integrates technical, infrastructure and business operations in a scalable,

reliable environment. MVNO customers can select the features and capabilities that meet their

business needs. Key features include:

• multiple underlying facilities-based wireless carrier networks (Sprint, Verizon, GSM);

• an integrated operating system, which includes provisioning, inventory management,

interactive voice response C'IVR'') systems, billing, reporting;

• device certifications, procurement, warehousing, logistics;

• program management and marketing;

• additional features to enhance user experience, such as free 411 and competitively

priced international long distance; and

• access to thousands of reload locations, ensuring that ETC end user customers will be

able to purchase additional services to complement their subsidized services.

Boorperang has direct control over the databases, systems and processes controlling the customer

records, usage records, and reporting. This provides us direct ability to implement current Lifeline

guidelines as well as evolve to meet future program policy requirements.

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Ready Mobile is a national brand distributed in over 30,000 retail locations.6 The expertise

developed to meet the rigorous operational demands of publicly traded, chain accounts (i.e.

Walgreens, CVS, Meijers) is foundational to delivering superior services to ETC and other white label

partners. Boomerang offers two wireless services under the Ready Mobile brand: ReadyMobilePCS

and ReadyBroadband. ReadyMobilePCS offers data access to consumers across the country via

smart phone technology using recycled, web-enabled phones with broadband data plans. Under the

brand ReadyBroadband, the company also provides data access through devices such as laptops,

notebooks, tower computers, and a wide array of other equipment. Both smart phones and access

devices are provided with national broadband coverage and distributed through national retail chains

as well as sold on the e-commerce site (www.readymobile.com).

Boomerang has direct, network carrier contracts with Sprint and Verizon and is negotiating a

contract with a national GSM provider as well. The multi-carrier wireless network platform provides

robust wireless service coverage across the entire ETC footprint. HH Ventures and its subsidiaries

have direct, in-depth experience with building voice, data and broadband products directly with

carriers.

Boomerang is experienced in providing broadband data access to consumers across the

country. Boomerang is poised to play a part in achieving the Commission's goal of expanding

broadband access to low-income consumers. Boomerang understands that low income consumers

are not early technology adopters. Accessibility and ease of use of Boomerang's products, services

and systems allows low-income consumers to take advantage of the power of wireless technology so

that we can close the digital divide. Adding data to phone plans is a growing trend in the low-

income base of customers, but as the Commission recognizes, lags behind the national norm.

6 The history of the Ready Mobile brand goes back to Ready Mobile LLC. Ready Mobile LLC was formed in 2005 and was focused on retail distribution of prepaid wireless products under the Ready Mobile brand name. In May 2007, Titan Global Holdings purchased certain assets from Ready Mobile LLC that included the Ready Mobile branding. Titan operated several other telecommunications ventures. HH Ventures participated in a transaction by which it purchased certain Titan assets, including the Ready Mobile brand on January 17, 2008. None of the Titan owners are part of the HH Ventures ownership.

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Boomerang will have data availability turned on in each handset distributed to Lifeline customers

that could become the subscriber's daily access to the Internet if they should choose to add data

services to their phone.

Because the Company already has in place nationwide distribution channels and activation

processes, it is ready to offer broadband access services to low-income consumers. The Company

has competitive billing plans for smart phones and other devices, including the ability to bundle data

services on smart phones along with voice and text services. Because of the Company's established

multi-channel, multi-partner approach, it has the ability to reach eligible consumers throughout the

country. In addition, Boomerang will advertise the availability and prices of its services through a

variety of mediums, including online advertising, direct marketing campaigns, print advertising,

event-based distribution, seminars, lectures, pamphlet distribution, and meetings with government

agencies.

Compliance Plan

This Compliance Plan describes the specific measures that Boomerang intends to implement

to achieve the objectives of the Commission's Lifeline rules and policies.

I. Policy

Boomerang will comply with all certification and verification requirements for Lifeline

eligibility set forth in the Lifeline Reform Order; the Commission's Lifeline rules and policies; the

requirements, rules and policies governing the provision of Lifeline service to eligible subscribers

residing on reservations or Tribal lands; the provisions of this Compliance Plan; and all laws and

regulations governing Boomerang's provision of Lifeline-supported prepaid wireless services to

customers throughout the United States.

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II. Unrestricted Access to Basic and E911 Services and Certification of Such Access

In the Lifeline Reform Order, the Commission stated that forbearance from the "own-

facilities" requirement is conditioned on a carrier seeking limited ETC designation "providing its

Lifeline subscribers with 911 and E911 access, regardless of activation status and availability of ~

minutes [and] providing its Lifeline subscribers with E911-compliant handsets and replacing, at no

additional charge to the subscriber, noncompliant handsets of Lifeline-eligible subscribers who

obtain Lifeline-supported services" starting on the effective date of the order.7 Moreover, wireless

resellers have an independent obligation to provide access to basic and E911 service, to the extent

that the underlying facilities-based licensee has deployed the facilities necessary to deliver E911

information to the appropriate Public Safety Answering Point.8 Resellers also have an independent

obligation to ensure that all handsets or other devices offered to their customers for voice

communication are location capable. 9

The Commission and consumers are hereby assured that all Boomerang Lifeline customers

will have available access to emergency calling services at the time that Lifeline service is initiated

and that such 911 and E911 access will be available from Boomerang handsets regardless of the

activation status and availability of minutes. Further, Boomerang will ensure that all handsets used

in connection with the Company's Lifeline service offering are E911-compliant. In the event that an

existing Boomerang customer does not have an E911-compliant handset, the Company will replace

it with a new 911/E911 compliant handset at no charge to the customer. Any new customer who

qualifies for and enrolls in the Lifeline program is assured of receiving a 911/E911 compliant handset

as well.

7 Lifeline Reform Order ~ 373. 8 See 47 C.F.R. § 20.18{m). 9 See id.

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III. Certification and Verification of Lifeline Customers' Eligibility

Boomerang proposes the following Compliance Plan to implement the certification and

verification conditions outlined in the Lifeline Reform Order. Boomerang intends to keep these

measures iii effect until the Commission implements its planned national eligibility database.

A. Policy

Boomerang will comply with all certification and verification requirements for Lifeline

eligibility established by states where it is designated as an ETC. In states where there are no state­

imposed requirements, no established rules or procedures in place, or in states that do not mandate

Lifeline support, Boomerang will obtain certification of eligibility at the outset and will verify

consumers' Lifeline eligibility in accordance with the Commission's requirements. Boomerang shares

the Commission's concerns about the potential abuse of the Lifeline program and is thus committed

to the safeguards stated herein, with the belief that these procedures will prevent Boomerang's

customers from engaging in such abuse of the program, inadvertently or intentionally.

B. Certification Procedures

Boomerang will implement certification procedures that enable consumers to demonstrate

their eligibility for Lifeline assistance to Boomerang employees or agents by contacting the Company

in person or via telephone, facsimile or the Internet. Although the specific process for each means

of contact differs slightly, as detailed below, regardless of the means of contact, at the point of sale,

consumers will be provided with printed information describing Boomerang's Lifeline program,

including eligibility requirements, and with instructions for enrolling. Consumers will be enrolled in

person or directed, via company literature, collateral or advertising, to a toll-free number and to the

Company's website, which will contain a linkto information regarding the Company's Lifeline service

plans, including a detailed description of the program and state-specific eligibility criteria.

Boomerang's application form will identify that it is a "Lifeline" application. Except in states in which

applicants are enrolled through a designated state agency, Boomerang will have direct contact with

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all customers applying for Lifeline service, either in person through its employees, agents or

representatives, or via the telephone (including facsimile) or mail.

Specifically, at events, Boomerang or enMarket personnel will explain the eligibility

requirements for the program, including participation in a qualifying program or earning income

below 135% of the Federal Poverty Guidelines and will verify the individual's eligibility. The

Boomerang or enMarket employees will also explain the program limitation of one Lifeline service

per household. In order to ensure potential customers are fully informed about the Lifeline program

and the eligibility process, Boomerang will provide a sufficient number of employees at each event

so that, while some individuals are handling the application and eligibility process with applicants,

other individuals are available to discuss the requirements with potential customers, answer

questions, identify appropriate documents and otherwise assist a customer in preparing for the

application/eligibility step. enMarket employees will begin educating potential subscribers as they

wait in line at events and explain the application process to prepare them. Employees are instructed

that the company has zero tolerance for waste, fraud or abuse, and that they should notify a team

lead immediately if they suspect that anyone might be providing false information or attempting to

obtain a duplicate Lifeline benefit for themselves or within the same household. At events, when a

potential subscriber reaches the front of the line, representatives will again confirm that no member

of the individual's household currently receives a Lifeline benefit from another carrier. The

representative will mention the name of major ETCs to assist applicants in determining whether they

already receive a Lifeline benefit. The representative will reiterate that Lifeline is a government

benefit, and that providing false information could subject the applicant to consequences including

penalty under perjury. After an applicant has completed the enrollment form, a representative will

check the CGM database to determine whether anyone at the same residential address currently

receives a Lifeline benefit. If so, the applicant will be asked whether the applicant is a member of a

separate household residing at the same address and to complete the form created by USAC to

certify that he or she resides in a separate household.

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At events, upon completion of the application, representatives will photograph the

documentation provided by the customer to prove identity and/or address and program- or income­

based eligibility. After this information is reviewed and possibly subject to a compliance audit,

described in more detail herein, Boomerang will maintain a record of the type of documentation

reviewed to determine eligibility, but will not keep the documentation itself. Finally, representatives

will review with the customer instructions in the welcome packet for activating the service or, if the

customer explicitly requests, will activate the handset at that time. Boomerang will not seek Lifeline

reimbursement until the customer has activated the handset.

Boomerang will also be promoting sign up through online outreach. Boomerang will use

search engine optimization and targeted ad placement to reach eligible low-income consumers. To

apply for a Boomerang Lifeline service online, a customer will fill out an application, provide the

necessary information that all prospective Lifeline customers must provide, and be taken through

forms and screens that clearly explain all relevant legal eligibility requirements. If the customer is

seeking to qualify for Lifeline service based on their participation in a particular program (or income

level), the prospective customer may be able to either upload the forms from scanned documents or

print off a Document Submission worksheet and submit the documents to Boomerang where a sales

representative will input the prospective customer's information into an eligibility database (if

available for the relevant state). However, in most cases, the prospective consumer will fill out the

relevant eligibility forms on the computer, and then send copies of the records needed by

Boomerang to verify the customer's eligibility to participate in Lifeline.

With the CGM database, all applications will be processed against the only national database

compiled with over 2 million current ETC Lifeline subscribers. This real time review will identify two

types of duplicate applications: individual duplicate (i.e. same SSN, Name, DOB, etc) or duplicate

residential addresses. If the entire record is a duplicate, the applicant will receive a message that

the application has been rejected. If the residential address is a duplicate, the applicant will receive

instructions regarding the definition of household and the opportunity to complete a verification that

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the applicant is a member of a unique household at that address that does not currently receive a

Lifeline benefit.

For all . application processes, Boomerang has an in-house Compliance Officer and

compliance metrics to further protect against waste fraud and abuse. This includes real time review

of application submissions during events and random sampling of online and paper submissions.

Boomerang's internal team will provide another layer of review (i.e., handwriting, submission

locations, timing) to identify abuse and carry out disciplinary action.

Once the prospective customer is successfully verified by Boomerang, Boomerang will enroll

the customer in the service plan selected by the customer, and then mail the selected handset to

the customer. Along with the handset comes a welcome packet with instructions for activating the

service. Boomerang will not seek Lifeline reimbursement until the customer has activated the

handset by following the instructions detailed herein or by making an outgoing call.

For potential subscribers who avail themselves of the toll-free number to apply for service,

the IVR script will emphasize the "one Lifeline benefit per household" restriction through its

interaction with the activating customer as well as review the 60 day non-usage rule and Annual

Recertification requirements. If a customer wants more information, they will be passed to a live call

center operator. Boomerang's sales training materials for call centers will include a discussion of the

one benefit per household restriction and the need to ensure that the customer is informed of this

restriction.

Boomerang will provide Lifeline-specific training to all personnel, whether employees, agents

or representatives, who interact with actual or prospective consumers with respect to obtaining,

changing or terminating Lifeline services. The training provides an explanation of the creation and

purpose of the Lifeline program, the source of funds to provide access to qualified low-income

consumers, program- and income-based eligibility determinations, and a detailed explanation of the

one-benefit-per-household limitation. The training emphasizes the importance of clearly explaining

the eligibility criteria and limitations to applicants as well as the potential consequences for providing

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false information on the application. Trainees learn what documentation is acceptable to verify

program- or income-based eligibility and that they must be able to communicate this information

clearly to applicants. Trainees are instructed to report to a supervisor if for any reason at all they

feel that an individual is trying to abuse the program or falsify eligibility. Trainees must ask an

applicant directly if they already have a Lifeline service, and more specifically, mention the names of

major Lifeline service providers in the geographic area, such as Safelink, Assurance, or Stand Up

Wfreless. Trainees are given instruction in checking the available duplicates database to confirm

whether anyone else at that residential address is receiving a Lifeline benefit, and if so, to ask the

applicant if multiple households reside at the same address. Trainees are also given instruction

about when to provide the additional household verification form on which the applicant will certify

that his or her household is a separate economic unit and does not already receive a Lifeline benefit.

Trainees are instructed on activation procedures and restrictions, including that an account may only

be activated by the subscriber or upon the subscriber's express authorization to do so.

Boomerang personnel will take steps to ensure that applicants are eligible to participate in

the Lifeline program. All personnel who interact with current or prospective customers will be

trained to assist Lifeline applicants in determining whether they are eligible to participate based on

state-specific income-based or program-based criteria. These personnel will be trained to answer

questions about Lifeline eligibility, and will review required documentation to determine whether it

satisfies state-specific eligibility requirements using state-specific checklists. Acceptable

documentation of program eligibility includes: (1) the current or prior year's statement of benefits

from a qualifying state, federal or Tribal program; (2) a notice letter of participation in a qualifying

state, federal or Tribal program; (3) program participation documents (e.g., the consumer's

Supplemental Nutrition Assistance Program (SNAP) electronic benefit transfer card or Medicaid

participation card (or copy thereof)); or (4) another official document evidencing the consumer's

participation in a qualifying state, federal or Tribal program.

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Acceptable documentation of income eligibility includes the prior year's state, federal, or

Tribal tax return; current income statement from an employer or paycheck stub; a Social Security

statement of benefits; a Veterans Administration statement of benefits; a retirement/pension

statement of benefits; an Unemployment/Workmen's Compensation statement of benefits; federal

or Tribal notice letter of participation in General Assistance; or a divorce decree, child support

award, or other official document containing income information for at least three months' time.

Boomerang will establish policies and procedures to review such documentation and keep accurate

records detailing how the consumer demonstrated his or her eligibility, including collecting

information on the enrollment form about what documentation the applicant presented to

demonstrate program-based or income-based eligibility. Where Boomerang personnel conclude that

proffered documentation is insufficient to establish such eligibility, Boomerang will deny the

associated application and inform the applicant of the reason for such rejection. In the event that

Boomerang personnel cannot ascertain whether documentation of a specific type is sufficient to

establish an applicant's eligibility, the matter will be escalated to supervisory personnel at

Boomerang's corporate headquarters.

Consumers who do not complete the application process in person must return the signed

application and supporting documentation to the Company by mail, fax, email or other electronic

transmission. The Company will accept electronic signatures that meet the requirements of the

Electronic Signatures in Global and National Commerce Act, 15 U.S.C. §§ 7001-7006, and any

applicable state laws, and may verify consumers' signatures via IVR systems. Processing of

consumers' applications, including review of all application forms and relevant documentation, will

be performed under the Company's supervision by managers experienced in the administration of

the Lifeline program.

The enrollment form will include a place where the applicant must certify by his or her

signature under penalty of perjury that the applicant meets the relevant criteria and that the

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applicant's representations are true and correct.10 Applicants will also be required to initial a number

of disclosure statements intended to ensure that the applicant understands applicable eligibility

requirements-including a statement to the effect that to the best of his or her knowledge, the

applicant is not receiving Lifeline-supported service from any other Lifeline provider. Penalties for

petjury will be clearly stated on the certification form. The certification will also contain language

stating that a violation of the one-per-household requirement constitutes a violation of the

Commission's rules and will result in the consumer's de-enrollment from the program, and could

result in criminal prosecution by the United States government. Although the exact wording of the

disclosure statements described above may vary on a state-by-state basis, depending on state-

specific requirements or consultations with relevant state agencies, Boomerang plans for the

disclosures to be consistent with the following statements:

__ The information contained within this application is true and correct. I acknowledge that providing false or fraudulent documentation in order to receive assistance is punishable by law.

__ I understand that Lifeline is only available for one benefit per household, whether landline or wireless. To the best of my knowledge, no one in my household is receiving Lifeline service. I will only receive Lifeline from Boomerang and no other landline or wireless telephone. company.

__ I am not currently receiving a Lifeline telephone service from any other landline or wireless telephone company.

__ I will not transfer my service to any other individual, including another eligible low­income consumer.

__ I understand that I may be required to verify my continued eligibility for Boomerang's Lifeline service at any time and that failure to do so will result in termination of Lifeline benefits.

__ I will notify Boomerang immediately if I no longer qualify for Lifeline or if I have a question as to whether I would still qualify.

In accordance with the Lifeline Reform Order, Boomerang will not retain copies of eligibility

documentation, but rather will maintain accurate records detailing how the customer demonstrated

his or her eligibility. Boomerang will check the eligibility of consumers seeking to enroll in Lifeline

10 A copy of Boomerang's proposed enrollment and certification form is attached at Exhibit B.

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either by accessing electronic eligibility databases, where available, or by reviewing documentation

from the consumer demonstrating his or her eligibility for Lifeline service. Where the Company is

able to access a state or federal database to make determinations about customer eligibility, the

Company or its representative will note in its records what specific data was relied upon to confirm

the consumer's initial eligibility for Lifeline. In instances where a state agency or third-party

administrator is responsible for the initial determination of consumer eligibility, Boomerang will rely

on the state identification or database.

Boomerang personnel will assist applicants in determining whether they are ineligible to

participate in the Lifeline program because a member of the applicant's household already is

benefiting from a Lifeline discount. Boomerang will establish safeguards to prevent individual

subscribers and households from receiving more than one benefit. Boomerang personnel will

explain in prominent, plain, easily comprehensible language to all new and potential subscribers that

no consumer is permitted to receive more than one Lifeline subsidy. Boomerang will emphasize the

one-per-household restriction in its contacts with potential customers. Boomerang personnel also

will inform each Lifeline applicant that he or she may be receiving Lifeline support under another

name, and facilitate the applicant's understanding of what constitutes "Lifeline-supported service,"

and ability to determine whether he or she is already benefiting from Lifeline support by identifying

the leading wireline and wireless Lifeline offerings in the relevant market by brand name.

Boomerang's Lifeline application forms will require each applicant to provide his or her name

and primary residential address and a billing address for the service if the consumer's billing address

differs from his or her residential address. The application form will clearly state that Lifeline

participants must provide their new address to the Company within 30 days of moving. Boomerang

will incorporate this information into its customer information database.

Prior to initiating service for a customer, the Company will check the address of each Lifeline

applicant against the CGM compiled database to determine whether or not it is associated with a

customer that already receives Boomerang Lifeline service, and will then review the application to

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ascertain whether the applicant is attempting to receive Lifeline-supported service for more than one

service associated with the address. Boomerang Wireless has aligned with CGM, LLC of Roswell,

Georgia, a Lifeline service bureau, to participate in the only national effort to match ETC applications

against current ETC participants. This recognized compliance software provider is working across the

industry to help minimize duplicate service to eligible households. CGM's growing database currently

includes more than two million of the 15 million current ETC subscribers. As of this writing, it is, to

Boomerang's knowledge, the largest pooled national database.

Boomerang has contracted with CGM to check each name/address combination against its

aggregate duplicate database to confirm that the applicant is not already receiving a Lifeline subsidy

from Boomerang or any other CGM client. The database dip is done simultaneously with customer

sign-up through an API connection between Boomerang's provisioning platform and CGM. This

check ensures that each applicant is not receiving a duplicate subsidy, as well as identifying those

customers who share an address with current Boomerang customers and, therefore, may warrant

further review. If Boomerang determines that an individual at the applicant's residential address is

currently receiving Lifeline-supported service, the Company will take an additional step to ensure

that the applicant and the current subscriber are part of different households. In order to make this

demonstration, Boomerang will require applicants to complete and submit to the Company a written

document developed by USAC consistent with the Commission's directions in the Lifeline Reform

Order.11 Boomerang will deny the Lifeline application of any such individual residing at the same

address as a current Lifeline subscriber who is part of the same household and will advise the

applicant of the basis for the denial.

Prior to requesting a subsidy, Boomerang, in conjunction with CGM, will process and validate

its subsidy data to prevent duplicate same-month Lifeline subsidies. Any household that is already

receiving a Lifeline subsidy will automatically be prevented from receiving a second Lifeline subsidy

in that same month. Boomerang will immediately de-enroll any subscriber whom Boomerang knows

11 See Lifeline Reform Order ~ 84.

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is receiving Lifeline-supported service from another ETC or knows is no longer eligible. Additionally,

each month, CGM will process and validate the Company's subsidy data to prevent: (1) duplicate

same-month Lifeline subsidies (Double Dip): any name/address that is already receiving a Lifeline

subsidy from the Company will be automatically prevented from receiving a second Lifeline subsidy

in that same month; and (2) inactive lines receiving subsidy. CGM's audits also compare all subsidy

requests to Boomerang's underlying carrier invoice to ensure that subsidies are requested only for

active lines. This process ensures that Boomerang does not request multiple subsidies from the

Universal Service Fund.

In addition, prior to requesting a subsidy, Boomerang will ensure that the customer has

activated the service in accordance with the Commission's requirements. Boomerang will provide

phone activation instructions in a welcome package provided with the handset and, at events, will

review these instructions with the customer. The activation process will allow the end user to

proactively establish service and have an opportunity to receive additional training on the device and

services available.

C. Procedures for Verification of Ongoing Consumer Eligibility

As required by the Commission's Lifeline Reform Order, Boomerang will require every

customer enrolled in the Lifeline program to verify on an annual basis that he or she receives

Lifeline-supported service only from Boomerang and, to the best of his or her knowledge, no one

else in the subscriber's household is receiving a Lifeline-supported service. Boomerang will submit

all required information to the relevant Tribal governments, as applicable, including its aggregated

re-certification data and annual re-certification results for subscribers residing on reservations or

Tribal lands. This re-certification may be done on a rolling basis throughout the year. Where

ongoing eligibility cannot be determined through access to a qualifying database either by the

Company or the state, and there is no state administrator verifying the continued eligibility of

Lifeline subscribers, the Company will recertify the continued eligibility of all of its subscribers by

contacting them- either in person, in writing, by phone, by text message, by email, or otherwise

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through the Internet-to confirm their continued eligibility. Such certifications may be obtained

through a written format, an IVR system, or a text message, in accordance with the Lifeline Reform

Order.12 In states where a state agency or a third party has implemented a database that carriers

may query to recertify the consumer's continued eligibility, the Company (or state agency or third

party, where applicable) will instead query the database and maintain a record of what specific data

was used to re-certify eligibility and the date of recertification.

Boomerang will notify each of its Lifeline consumers by mail that he or she must confirm his

or her continued eligibility in accordance with the applicable requirements. The notice will explain

the actions the customer must take to retain Lifeline benefits, when Lifeline benefits may be

terminated, and how to contact Boomerang. Boomerang will provide written notice of impending

service termination to subscribers who do not respond to the annual re-certification within 30 days.

Any subscriber who does not respond to the impending termination letter within 30 days to

demonstrate that his or her Lifeline service should not be terminated will be de-enrolled from the

Company's Lifeline program.

De-Enrollment for Ineligibility. If Boomerang has a reasonable basis to believe that one of

its Lifeline subscribers no longer meets the eligibility criteria, Boomerang will notify the subscriber of

impending termination in writing and in compliance with any state dispute resolution procedures

applicable to Lifeline termination, and give the subscriber 30 days to demonstrate continued

eligibility.13 A demonstration of eligibility must comply with the annual verification procedures found

in new rule section 54.410(f), including the submission of a completed and signed certification form.

If a customer contacts the Company and states that he or she is not eligible for Lifeline or wishes to

de-enroll for any reason, the Company will de-enroll the customer within five business

days. Customers can make this request by calling the Company's customer service number and will

not be required to submit any documents.

12 See Lifeline Reform Order ~~ 130, 132. 13 See Lifeline Reform Order, ~ 143; 47 C.F.R. § 54.405(e)(1).

-18-

IV. Additional Measures to Prevent Waste, Fraud and Abuse

A. Usage Requirement

Boomerang will implement policies and procedures to ensure that it does not obtain Lifeline

support for an inactive subscriber who has failed to use his or her service in the first instance or has

discontinued using the service.

Boomerang will not seek universal service support for a qualifying low-income consumer

until that individual subscriber uses the supported service to either activate the service or complete

an outgoing call. Boomerang will provide phone activation instructions in its event and online or

paper product packages. The activation process will allow the end user to proactively activate

service and have an opportunity to receive additional training on the device and services available.

Specifically, to activate service, customers will be instructed to call the Boomerang IVR, press "2" to

activate the phone, and enter a PIN included in the Welcome Instructions the subscriber receives

with the phone after the eligibility and enrollment process has been completed as described above.

At that point, the IVR will notify the consumer that the Lifeline account is active. The IVR will

inform the customer that the customer must use the service in order to keep the account active and

provide options through a menu for obtaining additional information about the phone or the service

and direct the customer to the Company's website for additional information. At in-person events,

Boomerang will assist an individual with account activation upon being expressly authorized by the

subscriber to activate the service.

To comply with the Commission's continued usage requirements, Boomerang will implement

a non-usage policy whereby it will de-enroll Lifeline customers that have not used the Company's

Lifeline service for 60 days. The customer will be given a 30 day cure period before they would be

de-enrolled from the Lifeline service. Boomerang will notify its subscribers at service initiation about

the non-transferability of the phone service, its usage requirements, and the de-enrollment and

deactivation that will result following non-usage in any 60-day period of time. If no usage appears

on a Boomerang Lifeline customer's account during any continuous 60-day period, Boomerang will

- 19-

deactivate Lifeline services fdr that customer after the 30 day notification & cure period. An account

will be considered active if during any 60-day period the authorized subscriber does at least one of

the following: makes a monthly payment; purchases minutes from Boomerang to add to an existing

pre-paid Lifeline account; completes an outbound call; answers an incoming call from anyone other

than Boomerang, its representative, or agent; or affirmatively responds to a direct contact from

Boomerang confirming that he or she wants to continue receiving the Lifeline-supported service.

Boomerang will take measures to continue to communicate with the customer to ensure the

customer understands the rules and requirements of the benefits. Boomerang has direct control

over customer databases and communication tools including: SMS messaging, outbound calling, IVR

messaging and direct mail communications. For example, if a customer has 45 days of non-usage,

Boomerang can text them to remind them about the.non-usage rules.

B. Consumer Education with Respect to Duplicates

As required by the Lifeline Reform Order, Boomerang will establish safeguards to prohibit

more than one supported service for each household. In addition to its verification and certification

procedures, and to better ensure that customers understand the Lifeline service restrictions with

respect to duplicates, Boomerang will implement measures and procedures to prevent duplicate

Lifeline benefits being awarded to the same household, including use and development of an

appropriate database.

Specifically, Boomerang personnel will emphasize the one-per-household restriction in their

direct sales contacts with potential customers. At the point of sale, potential customers will be

provided with printed information describing Boomerang's Lifeline program, including eligibility

requirements, and instructions for enrolling. As part of these printed materials, Boomerang will also

reinforce the one-Lifeline-benefit-per-household limitation. Materials from USAC, that have been or

will be developed pursuant to the Lifeline Reform Order, may also be provided at the point of sale as

dictated by a customer's responses. Boomerang will likewise reinforce and explain the one-per­

household restriction in its marketing materials. The Company will emphasize in plain, easily

- 20-

comprehensible language that: (1) Lifeline is a federal benefit; (2) Lifeline service is available for

only one benefit or subscription per household; (3) a household is defined, for purposes of the

Lifeline program, as any individual or group of individuals who live together at the same address and

share income and expenses; and (4) a household is not permitted to receive Lifeline benefits from

multiple providers. Boomerang will also include in its marketing materials (see Exhibit C)

substantially the following language in clear, easily understood language: the offering is a Lifeline­

supported service; that Lifeline is a government assistance program; that only eligible consumers

may enroll in the program; that documentation is necessary for enrollment; and the program is

limited to one benefit per household, consisting of either wireline or wireless service. Finally,

Boomerang will disclose the company name under which it does business and the details of its

Lifeline service offerings.

C. Internal Audit and Compliance Training for Boomerang Customer Service

In addition to detailed and thorough employee training, Boomerang will impose disciplinary

actions on employees who fail to abide by the requirements for determining eligibility for the Lifeline

benefit. Beyond the instructions for field and event training, Boomerang with provide its customer

service personnel with internal audit and compliance training. For incoming paper applications,

Boomerang will have a 100% compliance checklist to check applications for fraud and duplication.

The employee must check whether all fields on the certification and enrollment form are complete,

whether all necessary eligibility documents are attached, whether the eligibility documents align with

the information on the form, whether the handwriting is unique, whether all attestations are

initialed, and whether the form is signed.

For in-person and event outreach, in addition to the onsite eligibility determinations, a

Boomerang compliance officer will randomly check a representative sample of 3% to 10% of

applications as an additional check for errors or omissions or any sign of fraud. If the compliance

officer detects potential fraud or abuse in the application process, the affected applications will be

denied.

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V. Lifeline Offering

Boomerang's marketing efforts will be focused on finding and serving eligible consumers

using distribution models designed to reach the target population on a broad geographic basis.

Creating a trusted brand and service through community outreach is a primary methodology for

educating and soliciting customers. Boomerang will enroll Lifeline customers through several

different marketing channels. Boomerang's current business model and plans for providing Lifeline

service are based on reaching about 85% of its subscribers in person, through event marketing

targeting currently underserved populations. Boomerang anticipates that, while most of its outreach

will succeed via direct contact with consumers, potential subscribers will also be able to avail

themselves of a toll-free number (inbound telemarketing) or website to obtain enrollment

information. Boomerang also has plans to offer its services through retail stores and agents who

understand the underserved consumers in communities Boomerang would service as an ETC.

National retail chains have expressed interest in partnering with Boomerang to support the Lifeline

service and outreach to underserved eligible populations. Boomerang has partnered with retailers to

use parking lots as locations for event-based outreach.

enMarket, Boomerang's sister event marketing and distribution company, will use

demographic segmentation information to identify locations of populations with great need. The

neighborhood marketing program will reach Tier 3 and Tier 4 and smaller communities where the

population has not seen an influx of Lifeline service providers. enMarket will organize positive and

informative neighborhood events to create a local presence.

The Company has a long history with retail distribution. If Boomerang is granted ETC

designation, it is prepared to work with several national companies to explore unique, focused

Lifeline program marketing.

Boomerang will offer its Lifeline service in the states where it is designated as an ETC and

throughout the coverage area of its underlying carriers. Boomerang has direct underlying

agreements with Sprint and Verizon today. Negotiations are underway for the addition of a national

- 22 -

GSM provider. The company will use these network relationships to ensure a good product

experience for ETC consumers.

The Company's Lifeline offering will provide eligible customers with the following two Lifeline

plans: {l) 125 units that rollover where 1 minute equals 1 unit and 1 text equals 1 unit, and (2) 250

units without rollover where 1 minute equals 1 unit and 1 text equals 1 unit. Customers will have

the capability of purchasing additional bundles of minutes in the following denominations:

Denomination

Da s of Use

Minutes

Peak Minutes

NW Miniutes

Texts

Units Min+ Text

In addition to free voice services, Boomerang's Lifeline plans will include a free handset and

the following features: caller ID, call waiting and voicemail. Boomerang will turn on the data

capability for all of our handsets. This will allow customers to add a data plan to their phone service.

As a provider of Lifeline services to residents of Tribal lands, Boomerang will pass through

the full Tribal support amount to qualifying residents of Tribal lands, and under no circumstances

will it collect from the Universal Service Fund more than the rate charged to Tribal subscribers.

VI. Demonstration of Financial and Technical Ability to Provide Lifeline Services

Revised Commission Rule 54.202 requires carriers seeking designation as a Lifeline-only ETC

to demonstrate their technical and financial capacity to provide the supported service. Among the

factors that the Commission will consider are whether the applicant previously offered services to

non-Lifeline consumers, how long the applicant has been in business, whether the applicant intends

to rely exclusively on USF disbursements to operate, whether the applicant receives or will receive

- 23 -

revenue from other sources, and whether it has been subject to enforcement action or ETC

revocation proceedings in any state.

Boomerang's parent company, HH Ventures, is a privately held cash-flow-positive wireless

telecommunications holding company. HH Ventures has been providing prepaid wireless

telecommunications services to non-Lifeline subscribers since 2008. Its core management team

includes six senior executives with significant telecommunications experience, and the company

employs 40 full time employees.

Boomerang currently provides prepaid wireless services to more than 350,000 subscribers,

including more than 50,000 retail customers. The company currently provides a complete

wholesale, MVNE platform to several ETCs and other white label partners.

Boomerang does not intend to rely exclusively on USF disbursements to operate, as it

receives revenue from providing other services. For the 2011 calendar year, Boomerang and its

sister company received no direct USF reimbursement for Lifeline support; 17% of revenue was

generated from wireless resale services provided to ETCs, 14 52% of revenue was generated from

wireless retail services, and 31 % of revenue was generated from other non-regulated telecom

services. Boomerang has not been subject to enforcement actions or ETC revocation proceedings in

any state.

Boomerang certifies that it will comply with all of the requirements of newly amended

Commission Rule 54.202. Pursuant to Commission Rule 54.202(a)(l)(i) Boomerang certifies that it

will comply with the service requirements applicable to the support it receives. Further, Section

54.202 requires that an ETC demonstrate its "ability to remain functional in emergency situations,

including a demonstration that it has a reasonable amount of back-up power to ensure functionality

without an external power source, is able to reroute traffic around damaged facilities, and is capable

of managing traffic spikes resulting from emergency situations."

14 In 2011, Boomerang only entered into wholesale MVNE arrangements with designated ETCs. This year, Boomerang has entered into arrangements with other, non-ETC, white label partners.

- 24 -

Boomerang will remain functional in emergencies. Back-up systems are in place to ensure

full functionality in the event of a loss of power or network functionality. And, Boomerang's

switching facilities are housed in a carrier-class data center with fully redundant power and HVAC, a

controlled temperature and humidity environment, fire-threat detection and suppression, year-round

critical monitoring and secure access with biometric security. The facility features redundant

generators and redundant fiber optic connectivity. The data center is a reinforced concrete building

located in a secure area and collocated with the area electrical utility headquarters. It is powered

from separate paths independent of any one electrical generation plant. All systems within the

facility are implemented on redundant servers, each with redundant data network and power.

Direct carrier access with Sprint and Verizon networks provides additional tools to escalate

network or hardware issues encountered on a local or regional basis. Contractual arrangements

include direct escalation processes for tiered support depending on outage severity and number of

customers affected.

Section 54.202 also requires EfC applicants to demonstrate that they will satisfy applicable

consumer protection and service quality standards. Boomerang hereby commits to comply with the

Cellular Telecommunications and Internet Association's Consumer Code for Wireless Service.

- 25 -

Conclusio.n·

Boomerang's Compliance Plan meets the conditions set forth in the Lifeline Reform Order

and promotes public safety by ensuring. that Lifeline customers have access to 911 and E911

service. Boomerang requeststhat thE? Commission expeditiously approve the Company's Compliance

Plan and grant its pending ETC Petition so that Boomerang may begih providing the benefits of

Lifeline service to qualifying low-income consumers.

Respectfully .submitted,

July 26, 2012

. 26.